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Anti-Bribery and Corruption

We provide expert advice on the full range of international anti-corruption issues globally.

Our team includes former prosecutors in the U.S. and Europe and has worked on some of the most significant cases to date in the UK. Thanks to our past governmental and recent defence experience, our lawyers are known and respected by leading prosecutors and regulators in the U.S., Europe and the Asia Pacific region.

We routinely act on complex, multi-jurisdictional corruption matters. Our global reach gives us expertise in local law in multiple jurisdictions and the offices throughout our network work closely together. This is important because corruption investigations are usually cross-border and, because different legal systems and cultures vary in their regulatory regimes, and do not treat issues such as privacy, data protection, employee protection and privilege in the same way. Consequently, our lawyers are able to provide clients with well-rounded and insightful advice that addresses local issues as well as the risks to a global business that arise from cross-border investigations. We can credibly present this analysis to regulators across jurisdictions to protect our clients' positions.

We have a track record of handling significant, high-profile bribery and corruption issues for blue-chip multinationals including: assisting with policies and procedures; risk management; handling global investigations; and defence. We also regularly conduct due diligence into, and advise on strategies to deal with, foreign agents or intermediaries and mergers and acquisitions/joint venture targets.

Our experience of working on corruption matters with lawyers in jurisdictions where we do not have an office means that we are well placed to recommend trusted local counsel with specialist corruption expertise. Our established working relationships mean that we form integrated teams and are used to managing multiple parties to deliver a high-quality service efficiently.

News & insights

Publications: 02 OCTOBER 2019

GIR - data privacy & transfer in investigations

Regulators and enforcement authorities across the globe are continuing their focus on the activities of banks, corporations and their employees.

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Publications: 18 JULY 2019

U.S. continues aggressive sanctions and anti-money laundering enforcement against non-U.S. banks

When assessing anti-money laundering risk and exposure, global financial institutions should be mindful of the complex landscape and assertions of broad authority by U.S. authorities and banking regulators. A multinational financial institution with a U.S. branch may find its worldwide activities scrutinized by U.S. banking regulators even if its branch does not service those activities, and what’s more, even without a U.S. branch, a bank may still have civil or criminal U.S. exposure for payments cleared in the United States.

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Publications: 19 OCTOBER 2018

Bank ordered to disclose suspicious activity reports to customer

Lonsdale v National Westminster Bank [2018] EWHC 1843 (QB) (18 July 20181)  A bank was ordered to disclose, to a customer, suspicious activity reports (SARs) that the bank had sent to the National Crime Agency (NCA) at the time of freezing the customer’s bank accounts. The bank’s arguments concerning confidentiality, tipping-off and prejudicing an investigation were unsuccessful. The court’s observations on the interplay between the SARs regime and the law on data protection, defamation and breach of contract will be of interest to all banks. 

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Publications: 11 SEPTEMBER 2018

ENRC v SFO appeal: internal corporate investigation documents were protected by privilege

Documents, including interview notes, generated by mining company ENRC during an internal corruption investigation were protected by privilege and therefore did not have to be disclosed to the Serious Fraud Office (SFO).

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Investigations Insight

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A&O's blog highlighting the current issues

Focusing on the latest trends, risks and developments in business crime and financial services investigations.

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